2022 Code of Ethics - Page 33

ANTI-KICKBACK ACT
The Anti-Kickback Act prohibits subcontractors and potential subcontractors from giving kickbacks to prime contractors or their employees or to higher-tiered subcontractors or their employees . The Act also prohibits the acceptance of such kickbacks .
“ Kickbacks ” can be money , fees , commissions , credits , gifts , gratuities , or anything of value , which is either directly or indirectly provided in return for obtaining favorable treatment . Favorable treatment does NOT have to be something that you would think of as dishonest , but under different circumstances , might be considered an innocent act . It could include such activities as :
Awarding a subcontract or purchase order ;
Reducing contract requirements ;
Putting a supplier on the bidder ’ s list ;
Paying an invoice earlier than the company would normally pay it .
When the favorable treatment is “ bought ,” then it becomes unlawful . The Act prohibits any employee from :
Providing , attempting to provide , or offering to provide any kickback ;
Soliciting , accepting , or attempting to accept a kickback ;
Including , either directly or indirectly , the amount of any kickback in the contract price charged to our customers .
Your Responsibilities
Immediately report any requests to make , authorize , or agree to any offer or payment which is contrary to this Code to your supervisor and the BBNC Compliance Department .
Immediately report any information that makes you suspect that an employee or vendor is engaging in , or has engaged in , conduct prohibited by this Code to your supervisor and the BBNC Compliance Department .
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